Opening an Optical Shop in Maharashtra: The Licence Almost Nobody Mentions

Search for how to open an optical shop in India and you will get the same list every time: GST registration, a Gumasta licence, Udyam registration, a current account. All four are real. All four are also what you would need to open a shop selling anything at all.

The list is missing the one requirement that is specific to this trade, and it is the one with a government fee, a named form, and a qualified-person condition attached.

The one nobody lists: contact lenses are a medical device

If you intend to sell or even to stock contact lenses, you need a registration from the State Licensing Authority — in Maharashtra, the FDA.

Contact lenses are classified as a Class B medical device in CDSCO's classification list (Notice No. DCG(I)/Misc./2017(68), 29 June 2017). Since the Medical Devices (Fifth Amendment) Rules, 2022 — notified as G.S.R. 754(E) on 30 September 2022 — anyone selling, stocking, exhibiting or distributing a medical device needs a registration under the new Rules 87A–87D.

The part worth reading twice is the qualified person condition, Rule 87A(3)(v). Sales must happen under the supervision of competent technical staff, who must be one of:

• a degree holder from a recognised university or institution, or
• a registered pharmacist, or
• someone who has passed 12th standard with one year's experience dealing in the sale of medical devices.

Note what that is not. It is not an optometry qualification. Most shop owners assume this requirement demands an optometrist and either panic or ignore it; in fact a graduate, or a 12th-pass assistant with a year behind the counter, satisfies the rule as written.

There is a second thing worth understanding. The original Rule 87(1) pulled medical device sales under Part VI of the Drugs and Cosmetics Rules, 1945 — the full drug-sale-licence regime, which effectively expects a registered pharmacist. The 2022 amendment added Rule 87(1A), a lighter route for someone who holds no drug licence and sells medical devices exclusively. An optical shop that stocks contact lenses but no medicines is exactly the case that route was written for.

On lens solutions, I could not verify anything. I looked for a CDSCO classification entry, a gazette notification, or a provision in the Cosmetics Rules 2020 naming contact lens or multipurpose solution, and found none. I am not going to invent a classification for it. Ask your FDA office directly, because the answer determines whether the bottle on your counter sits inside or outside the registration you just applied for.

What about plain spectacles?

The word "spectacle" does not appear anywhere in CDSCO's classification list. Of ophthalmic items, only contact lenses, intraocular lenses, ophthalmic lasers and ophthalmic needles are classified.

So on the evidence, plain corrective spectacles, spectacle lenses and frames are not notified medical devices and are not caught by the MD-41/MD-42 requirement. Note the shape of that finding: it rests on absence from a list, not on a rule that says they are exempt. Some consultants will tell you an optical shop needs MD-42 regardless of what it stocks. If you sell only spectacles, get it in writing from the licensing office before you either pay for something you do not need or skip something you do.

The optometrist question, answered honestly

Almost every page on this subject asserts that you must employ a registered optometrist. Here is what I could actually establish.

The National Commission for Allied and Healthcare Professions Act, 2021 provides the framework, and Section 22 provides for State Councils. The Maharashtra State Allied and Healthcare Council was constituted on 10 October 2024, along with its 2024 Rules. So the council exists.

But the national Registration of Allied and Healthcare Professionals Regulations, 2025 were still a draft, out for public comment with a deadline of 25 October 2025. I could not confirm that they were finalised and notified after that. And I could find no Maharashtra law requiring an optical shop to employ a registered optometrist in order to do refraction.

The honest position as of September 2026: the machinery is being built, and it is not clear that mandatory registration is in force yet. Anyone telling you flatly that it is mandatory, or flatly that it is not, is more confident than the evidence supports.

The practical advice does not depend on resolving this. If you or your staff are doing refraction, get properly qualified anyway — because the rule will land eventually, because your competence is the product, and because a wrong prescription is a returned pair and a lost customer regardless of what the statute says. Check the council's own site before you rely on any of this; this is a fast-moving area.

Shops and Establishments: the threshold is ten, and most people get it wrong

Under the Maharashtra Shops and Establishments (Regulation of Employment and Conditions of Service) Act, 2017, what you must do depends on your worker count.

• Ten or more workers — full registration under Section 6. The certificate is valid for a period you request, up to a maximum of ten years, and is renewable; apply at least 30 days before expiry.
• Fewer than ten workers — intimation under Section 7. Not registration. An online submission to the Facilitator in whose jurisdiction the shop sits, with a self-declaration and self-certified documents, giving the employer's name, the establishment's name, the nature of business and the worker count.

Both are due within 60 days of starting business. Failing to file the Section 7 intimation carries a fine of ₹1,000. If your headcount later reaches ten, the whole Act applies to you from that point.

Both are done online through the Aaple Sarkar portal under the Labour Department. And "Gumasta" is simply the market's name for this — it is not a separate licence, and no government document uses the word.

Fees: I am not going to print a number. They sit in a schedule to the Rules, 2018 and vary with worker count, and I could not pull the current schedule from a primary source. Every figure you will find quoted online traces back to a consultant's blog. Check the schedule or ask the Facilitator.

GST: the ₹40 lakh number, and why the composition scheme is a trap here

For a supplier of goods in Maharashtra, GST registration becomes compulsory above ₹40 lakh aggregate turnover. (For services it is ₹20 lakh — irrelevant to a retail optical shop, but the two get conflated constantly.)

The composition scheme is available to a retail optical shop up to ₹1.5 crore turnover, at 1% of turnover — 0.5% CGST plus 0.5% SGST.

That sounds attractive and usually is not, for a reason specific to this trade. Under composition you cannot claim input tax credit and you cannot issue a tax invoice — only a bill of supply. Optical goods sit at 5% for corrective lenses and spectacles and 18% for frames and sunglasses, so you are paying real GST on your purchases and losing all of it. And a bill of supply cannot show the two-rate split that justifies charging 5% on part of a sale. If you have any B2B business at all — corporate spectacle schemes, insurance, tie-ups — those customers need a tax invoice and will go elsewhere. (The full rate position is here.)

Run the arithmetic with your CA rather than taking the 1% at face value.

Two things that catch people out

The plastic bag ban is real and it applies to retail. Maharashtra banned the manufacture, use, distribution, retail sale and storage of plastic carry bags — with and without handles — by notification dated 23 March 2018 under the Maharashtra Non-Biodegradable Garbage (Control) Act, 2006. A shop handing out plastic bags with every pair is not committing a technicality. Budget for cloth or paper from day one.

A municipal trade licence probably does not apply to you. Most city corporations in Maharashtra are governed by the Maharashtra Municipal Corporations Act, 1949, whose licensing provision (Section 376) targets enumerated dangerous and offensive trades — eating houses, storage of hazardous articles, certain manufacturing. General retail is not in that category. I am reasoning from the parallel provision in the Bombay Act rather than from your own corporation's schedule, so confirm with the ward office; but do not let a consultant sell you a trade licence without asking which entry in the schedule you supposedly fall under.

BIS: I found no Quality Control Order covering spectacle lenses, frames or sunglasses as of September 2026, so no mandatory BIS certification appears to apply. QCOs are added frequently — re-check before you import anything.

The order to do it in

Sequence matters more than the list, because two of these depend on the others.

1. Decide the constitution — proprietorship, partnership, LLP. Everything downstream carries this name.
2. PAN in the business name, if not a proprietorship.
3. Sign the premises. The address is required by almost everything that follows, so a registration done before you have a lease is a registration you will amend.
4. Shops & Establishments — Section 7 intimation or Section 6 registration, within 60 days. Aaple Sarkar.
5. Current account — needs the constitution proof and the Shops Act document.
6. GST registration — compulsory above ₹40 lakh, but register from the start if you will buy stock on credit and want the input tax credit. You cannot claim credit on purchases made before you were registered.
7. MD-41 → MD-42, if and only if you will stock contact lenses. Do this before the first contact lens shipment arrives, not after — the certificate is what makes the stock lawful, and it is decided in ten days.
8. Udyam registration — free, two minutes, and it is what makes you eligible for MSME payment-protection and most scheme benefits.

What it costs

I am not publishing my own opening figures. They are from one shop, in one city, in one year, and a number like that gets quoted back for a decade after it stopped being true. It would look authoritative and it would be misleading.

What is useful is the structure — which buckets exist, which ones people forget, and what your own numbers imply about how many pairs a month you have to sell.

Four things people leave out of the sum, in order of how much damage they do:

Your own salary. A shop that breaks even only because the owner works unpaid has not broken even. Put a real number in.

The working capital reserve. The first months are the slowest you will ever have, and the money to survive them is capital, not something you find later. Under six months of fixed costs is thin.

Opening stock at cost, not MRP. Obvious, and still the most common arithmetic error I see, because the price list in front of you is the retail one.

Loan EMI. Break-even on gross profit ignores principal repayment. If you are borrowing, add the EMI to monthly fixed costs before you read the break-even number.

Before you rely on any of this

Sourced, and current as of 8 September 2026:

• Contact lenses as Class B — CDSCO Notice DCG(I)/Misc./2017(68), 29 June 2017. Note that CDSCO's own document is headed "Draft" and I found nothing superseding it.
• MD-41/MD-42, Rules 87A–87D, fee and qualified person — G.S.R. 754(E), 30 September 2022.
• Shops Act Sections 6 and 7, the 60 days and the ₹1,000 fine — Maharashtra Act LXI of 2017.
• GST ₹40 lakh and composition at 1% up to ₹1.5 crore — CBIC, effective 1 April 2019.
• Plastic bag ban — notification of 23 March 2018.

Not established, and deliberately left open: the classification of contact lens solution; whether optometrist registration is actually in force in Maharashtra; the Shops Act fee schedule; whether your corporation's trade-licence schedule catches retail. If a consultant gives you a confident answer on any of those four, ask which document it comes from.

FAQ

What licences do I need to open an optical shop in Maharashtra? A Shops and Establishments intimation or registration, GST registration if you cross ₹40 lakh or want input credit, a current account, Udyam registration, and — if you will stock contact lenses — an MD-42 medical device sale registration from the state FDA. That last one is the trade-specific requirement and it is missing from almost every guide.

Do I need a licence to sell contact lenses in India? Yes. Contact lenses are a Class B medical device, and selling, stocking or distributing them requires a registration in Form MD-42 from the State Licensing Authority, applied for in Form MD-41 under Rules 87A–87D of the Medical Devices Rules, 2017. The fee is ₹3,000 and it is valid perpetually subject to a ₹3,000 retention fee every five years.

Do I need an optometrist to open an optical shop? Not established. The Maharashtra State Allied and Healthcare Council was constituted in October 2024, but the national registration regulations were still in draft as of late 2025 and I could find no Maharashtra law requiring an optical shop to employ a registered optometrist. Get qualified anyway — the rule is coming and the competence is the product.

What is the Shops Act threshold in Maharashtra? Ten workers. Ten or more means registration under Section 6; fewer than ten means an intimation under Section 7, which is a lighter online filing. Both are due within 60 days of starting business, and missing the intimation carries a ₹1,000 fine.

Is Gumasta a separate licence? No. Gumasta is the market's name for the Shops and Establishments registration or intimation. There is no separate document and no government form uses the word.

Should an optical shop take the GST composition scheme? Usually not, even though it is available up to ₹1.5 crore at 1%. You lose input tax credit on stock bought at 5% and 18%, and you cannot issue a tax invoice — only a bill of supply — which loses you every B2B customer and removes the two-rate split that justifies the 5% rate on part of a sale.

How much does it cost to open an optical shop? It varies enough by location and stock depth that any single figure is misleading. Use the calculator above with your own numbers; the buckets that matter are premises, equipment, opening stock at cost, registrations, and a working-capital reserve of at least six months of fixed costs including your own salary.

Written from opening and running a family optical shop in Maharashtra and from the instruments cited above, as they stood on 8 September 2026. Not legal or tax advice. Rules change; verify before you act.